Corrective Action Plans

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the fifteen students selected for enrollment reporting testing, two students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSLDS. In both instances, the data we had sent to the National Student Clearinghouse (NSC) was not received by NSLDS in a timely fashion. We will review our reporting schedule and make the appropriate changes to our reporting timeline to ensure the data we report to the NSC is subsequently received by NSLDS within regulations. Names of Contact Person Responsible for Correction Action: Frank Mullen, Associate Vice President of Financial Aid Anticipated Completion Date: November 14, 2024

Finding 2024-001 Failure to Meet the Standards for Safeguarding Customer Information Comments on Finding and Recommendation: The management of ICSW concurs with this finding. Actions Taken or Planned: ICSW plans to work closely with its various external, contractual partners for Information Technology and Financial Aid Services around items in the Gramm Leach Bliley Act to build out its policies and further strengthen the safeguarding of customer information. The plan is to have the completed during the fiscal year 2025. Michael Bauman Title: Vice President, Finance & Operations Telephone: (773)943-6503 Email: mbauman@icsw.edu

Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special tests and Provisions - Enrollment Corrective Action Plan: The Admissions and Records Office is currently responsible for reporting student enrollment to National Student Clearinghouse (NSC). Once enrollment is validated and certified, it is reported directly to the National Student Loan Data System (NSLDS). Grayson College does not report enrollment directly in NSLDS. The OFA requests a copy of the validated and certified NSC enrollment report from the Admissions and Records Office to double check accuracy by performing a random selection of students to confirm they have been reported correctly in NSLDS. If, for some reason, a student’s enrollment is not correct in NSLDS, the OFA contacts NSC to get an understanding as to why it is not reported correctly to NSLDS. This happens after each validated and certified cycle, including all module terms (8-week and mini-mester). The College is investigating how to conduct a batch validation, which will be more robust than the sampling method. GC Financial Aid staff have received additional training and understand the importance of V4 and V5 verification coupled with accurate reporting to the NSLDS. They are committed to making sure these actions as stated occur each semester. Name of Contact Persons: Carolyn Kasdorf - Vice President of Business Services. Stephanie Martin - Director of Financial Aid and Veteran Services Projected Completion Date: 2025

2024-002 Student Financial Assistance Cluster - Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The records identified with incorrect R2T4 calculations have been recalculated, reported to COD and funds returned. In order to best ensure policies and procedures for R2T4 calculations, additional staff have been trained to ensure calculations are checked and double checked to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson, Director of Financial Aid, Veteran Services & Student Employment Planned completion date for corrective action plan: All corrections have been submitted as of October 9, 2024. Training of additional staff in progress – to be completed by February 28, 2025.

CORRECTIVE ACTION PLAN: Staff transitions in Financial Aid and the Enrollment Center at the onset of the Fall 2023 term contributed to the later-than-usual submission/certification of First of Term enrollment reporting. Financial Aid and the Enrollment Center experienced staff shortages with resignations and leave. The initial fall enrollment (First of Term) was certified by the Institution and submitted to the National Student Clearinghouse (NSC) on October 18, 2024 within 60 days of the start of the term on August 21, 2023, but the National Student Loan Data Systems (NSLDS) did not receive the submission within the 60-day requirement. Although we anticipate this to be a one-time incident, to prevent any recurrence and ensure enrollment changes are reported to NSLDS within 60 days, Financial Aid provided additional staff training in the Enrollment Submission process, and Early Registration enrollment submissions will be submitted within the first week of classes with the First of Term enrollment submission sent during the third week of classes. Financial Aid also updated the Institution’s NSLDS profile to ensure that records submitted for NSLDS Transfer Monitoring and Financial Aid History are added to the Enrollment Roster submitted to NSC. Financial Aid and the Registrar established an updated policy to ensure that Financial Aid is informed of students who graduate after the graduation process runs each term. After that, the Registrar will report late graduations to the National Student Loan Data System (NSLDS) via the National Student Clearinghouse (NSC). Financial Aid updated the student in question’s graduation status in NSLDS. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate

CORRECTIVE ACTION PLAN: At Lewis & Clark, the Direct Loan acceptance process switched from affirmative confirmation to passive confirmation to streamline the student loan process for students. For loans accepted via affirmative confirmation, the loan notification must be sent no earlier than 30 days before and no later than 30 days after crediting the student’s account. The student or parent has 14 days from the notification date to request the loan cancellation. For loans accepted via passive confirmation, the loan disbursement notification must be sent no earlier than 30 days before or 7 days after crediting the student’s account. The student or parent then has 30 days from the date of the notification to request cancellation of the loan. Although the new timeline for a student to cancel a loan was reviewed prior to the process change to passive confirmation, Financial Aid neglected to update the notification letter at the time of implementation. The loan notifications now reflect the 30 days for loan cancellation. Cancellation requests of loan funds are processed promptly. Although the timeline to request a cancellation of all or a portion of a loan previously indicated a 14-day deadline, the Financial Aid office accepts most requests beyond the 14 to 30 days. However unlikely, if more than 120 days have elapsed since loan funds were disbursed, loan funds cannot be returned on the borrower’s behalf. In Spring 2024, Financial Aid established a process to send loan notifications in conjunction with weekly financial aid transmittals to ensure compliance with sending loan notifications within 7 days of crediting a student’s account. A Direct Loan transmittal report (TFAR-Transmitted FA Report) is generated through Colleague (ERP Software) weekly throughout each term, and loan notifications are emailed weekly to students whose student loans are credited to their accounts during that weekly process. To prevent Post-withdrawal disbursements of loan funds from updating and transmitting to student accounts before receipt of acceptance of post-withdrawal disbursements (PWD), upon completion of the Return of Federal Funds calculation, Financial Aid will delay updating student accounts until confirmation of acceptance within the established 14-day timeframe; this is a change from the previous practice of updating the student record and then denying the PWD until acceptance of loan funds. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate

2024-008- Student Financial Aid Cluster- (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2024 Condition Found In our testing of student files, six out of 40 students (15%) had enrollment statuses not timely or accurately reported to NSLDS. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-002. Corrective Action Plan The Registrar’s Office is updating its process for student location reporting. Further, until accurate graduate reporting can be confirmed, the Registrar’s Office will manually review graduates after conferrals are complete in January, June, and August. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Stephanie Connelley, Assistant Director of Records & Registration Implementation Date of Corrective Action Plan Location updates cannot be completed until the Spring term, according to NSC. Graduation reporting will be audited in January, June, and August.

2024-007 - Student Financial Aid Cluster- (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2024 Condition Found The College did not accurately complete refund calculations for 1 out of 9 students (11.1%) tested. Additionally, funds were not timely returned and withdrawal dates were not timely determined for three out of nine students (33%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-003. Corrective Action Plan Montreat College is reviewing the faculty record-keeping process and the Registrar's Office’s Last Date of Attendance (LDA) data confirmation. LDAs must be reported accurately and reported in a timely manner. Student Financial Services is developing a two-person process where two staff members review all Return to Title IV funds (R2T4). Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Stephanie Connelly, Assistant Director of Records & Registration Marie Wisner, Associate Dean for Calling & Career Montreat Cabinet Implementation Date of Corrective Action Plan June 30, 2025

2024-006 - Student Financial Aid Cluster- (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2024 Condition Found The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 40 students in the sample (5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Corrective Action Plan Student Financial Services will work with PowerFaids to determine how records are returned to COD for a disbursement date update and ensure reporting is compliant. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan January 31. 2025

2024-005 - Student Financial Aid Cluster- (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2024 Condition Found During our student file testing, we noted five students out of 40 (12.5%) did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be a significant deficiency with the Eligibility Compliance Requirement. Corrective Action Plan Student Financial Services will develop a report and process that looks at students with a withdrawal or conferral date in Jenzabar or who have dropped below half time, who have taken Direct Loans and ensure that exit counseling materials are sent. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan March 31, 2025

2024-004 - Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education ALN No. (a) 84.007 (b) 84.033 (c) 84.038 (d)84.063 (e) 84.268 - Year Ended June 20, 2024 Condition Found 5 of the 40 student files (12.5%) we examined, we noted the students were not properly awarded Direct loans. Corrective Action Plan Student Financial Services has created a report comparing need-based aid awarded to the student’s need eligibility and an overall aid awarded compared to the Cost of Attendance (COA) budget. We will also work to develop a report that compares FAFSA year in school compared to total credit hours earned. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan January 31, 2025

2024-003 - Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (t) 84.379 - Year Ended June 20, 2024 Condition Found One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants. Corrective Action Plan The Student Financial Services Office will implement a weekly task of reviewing students in a Disbursement Review (DR) status and students with zero credits in a term with an active Period of Enrollment (POE). Responsible Person for Corrective Action Plan Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan December 1, 2024

Corrective Action Plan December 19, 2024 Federal Audit Clearinghouse Northern Tier Career Center respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: EFPR Group, CPAs, PLLC Certified Public Accountants 8 Denison Parkway East Corning, NY 14830 Audit period: July 1, 2023 – June 30, 2024 The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT FINDING 2024-001 – Student Financial Aid Cluster – Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.286 and 84.063; Grant Period - For the year ended June 30, 2024 Condition: The School does not have a written information security program containing the required minimum elements including the designation of a qualified individual who is responsible for implementing and monitoring the School’s program. Criteria: The School is required to have a written information security program that includes the required minimum elements including designating a qualified individual who is responsible for implementing and monitoring the School’s program. Cause: The School did not have a written information security program containing the required elements. Effect of Condition: The School was not in compliance with the requirement to have a written information security program that includes the required minimum elements including designating a qualified individual who is responsible for implementing and monitoring the School's program Questioned Costs: None. Recommendation: The School should designate a qualified individual responsible for implementing an monitoring the School's information security program. This individual should put procedures in place to create a written information security program that addresses the required minimum elements required by the Student Financial Aid cluster included in the Gramm-Leach-Bliley Act - Student Information Security. Views of Responsible Officials and Planned Corrective Actions: NTCC is in the process of a First Reading Policy on or before February 20, 2025, and a Second Reading Policy for full approval on or before March 20, 2025. This policy will name the Practical Nursing Coordinator, as the individual responsible for implementing and monitoring the School’s security program. The seven required minimum elements for a financial institution of fewer than 5,000 customers will be in place with this policy. Contact Person Responsible for Corrective Action: Colleen Edsell, Business Administrator. Anticipated Completion Date: The corrective action plan will be completed by March 20, 2025. If the Federal Audit Clearinghouse has questions regarding this plan, please call Colleen Edsell at 570-265-8111. Sincerely yours, Gary Martell, Director

FISAP Reporting Planned Corrective Action: In partnership with our third party servicer, we have contracted there independent review of the 25-26 FISAP report prior to submission to ensure all figures are accurate. We will coordinate with the Department of Education to correct errors related to Pell reporting on the 24-25 FISAP. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025

Verification Planned Corrective Action: We have contracted a third party servicer to complete and review verification for the current academic year to ensure accuracy and completion. We will establish an a process for periodic audits will be conducted to verify the accuracy of all completed verifications for students flagged. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025

Untimely and Inaccurate Returns of Title IV Funds (R2T4) and National Student Loan Data System Updates (NSLDS) Planned Corrective Action: We will provide additional training to financial aid staff on Return to Title IV (R2T4) processing from a third party servicer with expertise in processing with our current financial aid management system. We will also collaborate with the Registrar’s Office to implement a system that ensures timely notification of student withdrawals, enabling the financial aid office to process R2T4 returns within the required timeframe. We will establish more robust internal controls to verify that withdrawals are correctly updated in NSLDS, and review staffing needs to ensure adequate resources for processing Title IV aid returns efficiently. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025

Finding 2024-003 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 1 student was not reported to the COD system within 15 days of disbursement. Corrective Action Plan: The Director of Financial Aid will: • Review and update the disbursement reporting process to ensure timely and accurate reporting to COD and agreement with college records. • Train staff on the new process. • Conduct a second check on COD reports within 14 days for student files with FAFSA-related holds or delays to ensure accuracy. Responsible Individual(s): Christopher Natelborg, Director of Financial Aid Anticipated Completion Date: February 2025.

Finding 2024-002 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 9 students did not receive a timely notification of their award from the College Corrective Action Plan: The Director of Financial Aid will implement procedures to ensure timely notification of financial aid awards: • In August 2024, the Director collaborated with IT to fix a notification system glitch. • IT added a control that sends an email alert to IT, the Director, and tech support if there is a mismatch between student IDs for loan disbursement and notifications sent. This ensures immediate review and resolution of any missed notifications. Responsible Individual(s): Christopher Natelborg, Director of Financial Aid Anticipated Completion Date: February 2025.

Finding 2024-001 Significant Deficiency in Internal Control over Compliance and Other Matters Odessa College will implement the following to ensure compliance with federal regulations, improve internal processes, and prevent future occurrences. Additionally, the college is moving forward with comprehensive financial aid advisory services with Ellucian, the College’s enterprise student information system. The engagement/advisory priorities include establishing an R2T4 Process that complies with the 45-day reporting requirement. The engagement period is contracted for the next 14 months. Review and Update Withdrawal Procedures:  Conduct a comprehensive review of current student withdrawal procedures to identify any weaknesses or delays in processing withdrawal dates and the return of Title IV funds.  Ensure that the withdrawal process is thoroughly documented, and that all departments (registrar, financial aid, student accounts) are aligned on their responsibilities related to withdrawal processing. Strengthen Communication between Departments:  Establish a clear communication protocol among the registrar’s office, financial aid office, and student accounts to ensure that withdrawals are processed promptly.  Designate specific individuals to monitor the return of Title IV funds and ensure deadlines are met.  Implement an internal checklist for verifying that all Title IV funds are returned within the required time frame. Implement a Monitoring System:  Set up an automated system or a shared calendar to track Title IV refund timelines for students who withdraw.  Use alerts or reminders to notify responsible staff members when a Title IV refund is due to be returned within the 45-day window.  Monitor and document all returns of Title IV funds to maintain compliance. Staff Training:  Conduct training for staff involved in student withdrawals, financial aid, and compliance to ensure they are knowledgeable about the 45-day return requirement and the importance of adhering to it.  Include a review of the audit finding and corrective actions during departmental Develop a Compliance Audit Checklist:  Create a detailed audit checklist for Title IV refund procedures to be used in periodic internal audits to ensure that all financial aid disbursements, returns, and related processes comply with federal regulations.  Review the checklist regularly to ensure the process is effective and compliant with regulatory changes. Monitoring and Reporting:  Schedule and conduct regular internal audits of Title IV funds return procedures and withdrawal processes to ensure ongoing compliance.  Review audit findings, staff performance, and timelines to identify potential areas for improvement. Compliance Reporting:  Prepare a report for the administrative team outlining corrective actions taken, including the return of funds, updated procedures, and staff training. Responsible Officials: Kim McKay – Vice President Student Services Anticipated Date of Completion: May 2025 meetings to reinforce the importance of compliance.

FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure file documentation would identify students in the return funds population. Plan: South Suburban College established a control process to assist with remaining in compliance as stated in the Single Audit Report Finding 2023-003 Corrective Plan. South Suburban College’s Financial Aid Department used Information Technology reports to retrieve the college’s Return of Title IV funding (R2T4) population, it was found that the reporting files were incorrect. Therefore, the Director of Financial Aid, Financial Manager will review the student population list provided by IT to ensure the population consist of financial aid eligible students who withdrew from all enrolled courses. The Director of Financial Aid will continue to work with the Information Technology Department to enhance the retrieval of the Return of Title IV funding student populations reporting process through Ellucian Colleague per the 2023 Correction Plan.

FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The college accepts this finding and has implemented the corrective plan below. The error was remedied by correcting the enrollment dates in the Colleague student information system. Plan: South Suburban College has and will continue to review procedures to identify areas of improvement for attendance reporting to ensure funds are returned accurately and timely. Enrollment dates will be confirmed and entered in the Colleague system prior to the start of academic year by the Financial Aid Director and Financial Aid Manager to support accurate return of funds calculations. This corrective plan has been implemented. Anticipated Date of Completion: 1/31/2025 Name of Contact Person: Yolanda Freemon

FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Management’s Response: The College accepts this finding and has implemented the corrective plan below to reinforce established procedures regarding timely submission of COD information. The error was caused by the cyber incident which delayed submission. Plan: South Suburban College established a control process to assist with remaining in compliance with COD submissions as stated in the Single Audit Report Finding 2023- 003 Recommendation section. In addition, cross-training of the Financial Aid Manager and Financial Aid Coordinator to support timely COD submissions and Pell disbursements was provided. Currently, the disbursement process of PELL consists of weekly submissions by the Financial Aid Coordinator who also requests and reconciles Pell funds in COD. The Financial Aid Director provides additional review of the Pell disbursement lists to ensure accuracy of the awards. This corrective plan has been implemented. Date of Completion: 8/21/2024 Name of Contact Person: Yolanda Freemon

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid Office will include weekends in the break days identified in the Return to Title IV schedules created on the COD.gov site. All federal aid will be included in R2T4 calculations. These two issues which came out in the audit were resolved and implemented before the fall 2024 semester. Another person will review the R2T4 form before the process is finalized. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 08/15/2024

Ineligible Disbursements Planned Corrective Action: The Financial Aid Office will review the credit hours earned for each student to ensure the federal loan amounts awarded are appropriate for the number of hours the student earned. This will be done before the beginning of each semester and after final grades have been posted. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 12/9/2024

Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid runs a query once a month to find students who have received Title IV or state aid and have withdrawn. The student in question did not appear on the query when we believe they should have, but was on the subsequent report. We have changed our procedures to run the query and complete Return to Title IV calculations weekly, rather than monthly. We believe this will help us find any discrepancies more quickly. We also reviewed the query and made some edits to attempt to increase accuracy. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid Implementation Date: 09/01/2024